Construction Dewatering Permitting & Streamlining September 11, 2017

Transcription

1 Construction Dewatering Permitting & Streamlining September 11, 2017 Ed Abbasi, P.E. King County Industrial Waste Program Seattle, WA (206)

2 King County Wastewater Treatment Division 34 local sewer agencies (cities & sewer districts) 420 square miles 1.5 million people 3 Regional plants (West & South Plants, Brightwater) 2 local plants (Carnation & Vashon Island) 42 Pump Stations 389 miles of conveyance lines 38 Combined Sewer Overflows (CSO s) and 4 CSO treatment facilities Average 175 million gallons per day (MGD) treated wastewater

3 King County Industrial Waste: What We Do Since 1969, the King County Industrial Waste Program has administered regulations for businesses discharging wastewater into King County's sewage system. We work cooperatively with more than 650 industrial users to: Regulate Provide technical assistance Protect biosolids, water quality, POTW, and health and safety of sewer workers, and Equitably recover treatment and program costs. 3

4 KCIW Works With Many Industries Metal finishing / Electroplating Pharmaceutical manufacturers Can makers Iron manufacturing Centralized waste treatment Food processors Contaminated stormwater Construction dewatering 4

5 Construction Dewatering King County During construction, workers pump groundwater, process wastewater and contaminated stormwater away from the site. This water may be sent into the sewer only if authorized by King County and the local city or local sewer agency.

6 Construction Dewatering We accept construction wastewater under some conditions Sewer connections must be approved by the LSA. LSA sets conditions for: Discharge point(s) Maximum discharge rate (gpm) Reporting procedures to determine sewer fees. 6

7 Construction Dewatering Authorization Types of Authorizations Letter of Authorization (Small uncontaminated flows, monitoring not required, KCIW does not perform preoperative inspection) Minor Authorization (Small uncontaminated flows, monitoring required and shall be kept on site, KCIW does perform preoperative inspection) Major Authorization (Larger flows with some contaminations, monitoring and reporting required, KCIW does perform preoperative inspection) Permit (Larger flows with significant amount of contaminations, monitoring and reporting required, KCIW does perform preoperative inspection and sampling) 7

8 A permitting problem: Lots of work; little benefit Contractors KCIW Local agencies Use the same time and resources to permit both small and large construction projects The impact on the wastewater system from small projects is minimal.

9 What could be the problem? Long issuance process (For smaller projects 2-8 weeks) Same effort spent on large and small projects Inconsistency and confusion (too many types of authorizations) Incomplete applications And more. 9

10 How to Streamline? Interviewed KCIW investigators Interviewed stakeholders and customers Internal agencies within King County Large and small contractors WS-DOT Seattle-DOT Reviewed active authorizations for smaller and relatively cleaner sites 10

11 Streamline Process & Findings About 40% of the construction permit applications come from small and clean sites discharging less than 25,000 gpd Many of these are short term projects (<6 months) KCIW write each approval individually Remaining 60% Small, Clean Sites 40% 11

12 Streamline Process / Findings The Remaining 60% of applications are for projects that are: >1 acre >25,000 gpd 1 year < Duration <5 year Moderately to high contamination Remaining 60% Small, Clean Sites 40% 12

13 Streamline Process Guiding Principles 13

14 Phase I - General Authorization Question Is it possible to offer a General Authorization using the Presumptive Approach similar to the Ecology Construction Stormwater General Permit? Answer: Yes, we can. Small, Clean Sites 40% We call it: General Letter of Authorization (GLA) 14

15 Phase I The Presumptive Approach for General Authorization What the Presumptive Approach Requires? Pre-approved and appropriate BMPs on site Site must be less than an acre Site must not be contaminated The discharge must be less than 25,000 gpd Small, Clean Sites 40% 15

16 Phase I The Presumptive Approach Presumptive approach is consistent with 40 CFR (k)(3). It relies on proven BMPs prescribed by King County Industrial Waste (KCIW) Guidelines, instruction, graphics, and design basis for settling tanks are provided on King County s websites for public use. /industrial-waste.aspx Small, Clean Sites 40% 16

17 Phase I - How General Authorization Was Developed? Developed a simpler application form Developed template Expanded KCIW Webpage Developed FAQs Small, Clean Sites 40% 17

18 Phase I - Benefits of Streamlining Shorter and simpler application for small projects Quicker turn-around time (within 1 week or less) Less back & forth between King County, LSA, and builders No reporting requirements (monitoring data kept on site) Protects water quality and biosolids, and Saves time & Lowers the costs Supports the regional economy Superior customer service Small, Clean Sites 40% 18

19 Steps to Receive General Authorization Confirm if LSA accepts construction wastewater. Consult with KCIW. Select and download appropriate application: i.e., General or Individual. Submit to KCIW completed application Receive from KCIW authorization. Contact LSA for discharge point(s) and other requirements. 19

20 Construction Dewatering Streamlining Phase 1 How is it working? Since March 2016 >120 issued Conducted random inspections Generally in good compliance Receiving positive feedbacks from customers

21 Phase II Discharge Authorization Redefine Significant Industrial User (SIU) for Construction Wastewater for each POTW West Point About 90 mgd during the dry months The Other 60% Provides secondary treatment for about 300 mgd during wet season Provides primary treatment and disinfection for flows exceeding 300 mgd and up to 440 mgd West Point > 250,000 gpd 21

22 Phase II Discharge Authorization Redefine Significant Industrial User (SIU) for Construction Wastewater for each POTW South Treatment Plant About 90 mgd during the dry months Up to about 300 mgd during wet season The Other South Treatment > 200,000 gpd 22

23 Phase II Discharge Authorization Redefine Significant Industrial User (SIU) for Construction Wastewater for each POTW Brightwater Treatment Plant Brightwater treats an average of 36 mgd By 2040, the treatment capacity may be expanded to 54 mgd Brightwater > 50,000 gpd The Other 23

24 Phase II Discharge Authorization Identified pollutants of concern Settleable Solids, ph, Oil & Grease Sulfides Organic Compounds Dry cleaning based Petroleum based The Other Other compounds 24

25 Phase II Discharge Authorization A new Ranking Criteria is based on Duration of Discharge Simultaneous Point of Discharge Maximum daily discharge volume gpd Presence of Combined Sewer System The Othe The Ranking Criteria is used to decide DA vs. Permit 25

26 Ranking Criteria 26

27 Phase II Discharge Authorization Form updates New Application & Inspection Form New Ranking Criteria New Template with, Consistent Language Pre-defined monitoring & reporting frequency for each treatment plant Pre-defined concentration and loading limits The Other 60% 27

28 When Q < SIU & Contaminants Present 28

29 When Q > SIU & no Contaminants Present 29

30 Phase II Discharge Authorization Outcome Fewer Authorization Types: GLA, DA or Permit Greater Standardization & Consistency Quicker Turnaround and Superior Customer Service GLA (within 1 week or less) DA (within 1 month or less) Permit (within 2-3 months) Superior Customer Service The 30

31 Thank you. Questions? Ed Abbasi, P.E. (206) Department of Natural Resources and Parks KSC NR South Jackson Street, Suite 513 Seattle, WA

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